- 8 -
hearing only if the person did not receive a notice of deficiency
for the taxes in question or did not otherwise have an earlier
opportunity to dispute the tax liability. See Sego v.
Commissioner, 114 T.C. 604, 609 (2000); Goza v. Commissioner,
supra. Section 6330(d) provides for judicial review of the
administrative determination in either the Tax Court or Federal
District Court.
Petitioner challenges the existence of the asserted tax
liabilities for 1995 and 1996 on the grounds that she did not
receive income from a taxable source and respondent failed to
demonstrate that she is liable for Federal income taxes.
Although respondent determined that the income in question is
attributable to taxable wages, petitioner never identified the
alleged nontaxable source of the income, nor did she expressly
deny receiving the wages in question. The record shows that
Appeals Officer Johnson gave petitioner every opportunity to
produce documentation in support of her position.
Petitioner’s arguments that she is not subject to Federal
income taxes and that she did not earn taxable income during 1995
and 1996 are frivolous and groundless. Goza v. Commissioner,
supra. As the Court of Appeals for the Fifth Circuit has
remarked: “We perceive no need to refute these arguments with
somber reasoning and copious citation of precedent; to do so
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
Last modified: May 25, 2011